Most likely, consultants will not be considered investigators and will therefore not be affected.聽 If consultants, who are not 91探花employees, are investigators on a 91探花project, they will likely be contracted through their academic institution, rather than personally. The subawardee, whether through purchasing or a subcontract, will be required to have a compliant policy in order to get federal funding. To meet the mandatory training requirement, an investigator who is not 91探花personnel could take our training, via a .